* Office of Inspector General
Report of Audit
Regional Laboratories
Audit Report No. E1PMF6-05-0115-7100277
August 20,1997
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Inspector General Division
Conducting the Audit: Northern Audit Division
Chicago, Illinois
Anthony C. Carrollo, Divisional
Inspector General
Charles M. Allberry, Audit Manager
Janet G. Kasper, Team Leader
Jori L. Spolarich, Auditor-in-Charge
Michelle L. Pienta, Auditor
Program Covered: Regional Laboratories
Program Offices Involved: Office of Regional Operations and
State/Local Relations
Regions 1 through 10
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
OFFICE OF
THE INSPECTOR GENERAL
August 20, 1997
SUBJECT: Audit Report No. E1PMF6-05-0115-7100277
Audit of Regional Laboratories
FROM: Michael Simmons
Deputy Assistant Inspector General
for Internal Audits
TO: Mary Louise Uhlig
Acting Associate Administrator for
Regional Operations and State/Local Relations
Attached is the report on our audit of regional laboratories. The purpose of the audit was to evaluate
the planning and management of regional laboratories. We concluded that, along with other EPA
offices, the regional laboratories needed to improve the systems for planning, measuring, and reporting
on activities they performed in order to meet the requirements of the Government Performance and
Results Act. We also concluded that the laboratories needed a stronger shared identity and national
leadership.
ACTION REQUIRED
In responding to the draft report, your office provided corrective actions, with milestone dates, for
each recommendation. Therefore, no further response is required, and we are closing this report in our
tracking system. Please track all corrective actions in the Management Audit Tracking System.
We have no objections to the further release of this report to the public.
We appreciate the cooperation you, your staff, and the regional laboratories provided during this
review. Should you or your staff have any questions, please contact Charles Allberry, Audit Manager,
Northern Audit Division, at 312-353-4222 or Richard Hall, Headquarters Liaison at 202-260-5563.
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EPA's Regional Laboratories
EXECUTIVE SUMMARY
INTRODUCTION
OBJECTIVES
RESULTS-IN-BRIEF
The Office of Inspector General (OIG) performed an audit of the
Environmental Protection Agency's (EPA) regional laboratories.
Although prior OIG reports have addressed the Agency's Office of
Research and Development laboratories, there have been no recent
reports concerning the management of regional laboratories.
The objectives of this audit were to:
• determine whether improvements were needed in how regional
laboratories' activities were planned and managed, and
• identify areas where administrative processes among regional
laboratories could be streamlined.
To meet the Government Performance and Results Act of 1993 (the
Results Act), EPA is taking steps to improve the processes for planning,
program evaluation, budgeting, and fiscal accountability. The regional
laboratories' current processes will not be adequate to assist the Agency
in meeting the Results Act. Areas for improvement include: (1)
preparing performance plans, (2) measuring performance, (3) increasing
accountability, and (4) linking planning and performance to funding
levels. See chapter 2 on page 5 for details.
EPA's regional laboratories need a stronger shared identity and more
active national leadership. Each regional laboratory has historically
operated independently of the others; however, there are many
similarities in their missions, goals, and contributions to the Agency. A
1994 EPA report1 (1994 Laboratory Study) recommended enhancing the
role of the "central advocate" for the regional laboratories and re-
evaluating which organizational component should fill that role.
Although the Office of Regional Operations and State/Local Relations
(OROS/LR) was designated to perform this role, its ability to fulfill the
responsibilities had been limited. The absence of a shared identity
among regional laboratories and the limited scope of national leadership
Research. Development, and Technical Services at EPA: A New Beginning. Report No.
EPA/600/R-94/122, July 1994.
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have resulted in inefficient efforts to meet common needs. See chapter
3 on page 13 for details.
AGENCY ACTIONS
OIG EVALUATION
The Acting Associate Administrator for OROS/LR stated that
OROS/LR and the regional laboratory managers have joined the Agency
in its efforts to understand and implement specific requirements and
goals of the Results Act. The managers recognize the importance of
both planning and accountability and will continue to bring their
processes in line with the requirements of the Results Act. Concerning
the concept of shared identity for the regional laboratories, OROS/LR
will work with the laboratories to achieve greater consistency and
effectiveness through more coordinated efforts. As the current
reorganization of the Office of Administrator is completed, its regional
operations staff will work to acquire the resources necessary to provide
strong national leadership for the broad scope of issues vital to the
regional laboratories. See pages 11 and 19 for specific actions the
Agency will take to address the findings and recommendations.
The Agency's actions, when completed, will address the findings and
recommendations in the report.
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Table of Contents
EXECUTIVE SUMMARY i
ABBREVIATIONS iv
CHAPTERS
1 INTRODUCTION 1
Purpose 1
Background 1
Scope and Methodology 3
Prior Audit Coverage 4
2 IMPROVEMENTS NEEDED TO MEET THE GOVERNMENT PERFORMANCE AND
RESULTS ACT 5
Government Performance and Results Act 5
Current Practices Need Improvement 6
Conclusion 11
Recommendations 11
Agency Actions 11
OIG Evaluation 12
3 REGIONAL LABORATORIES NEED A STRONGER SHARED IDENTITY AND
NATIONAL LEADER 13
Shared Identity 13
National Leadership 14
Illustrations of Need for National Leadership 16
Conclusion 18
Recommendations 19
Agency Actions 19
OIG Evaluation 19
APPENDICES
1 OFFICE OF REGIONAL OPERATIONS AND STATE/LOCAL
RELATIONS RESPONSE TO THE DRAFT REPORT 20
2 DISTRIBUTION 23
in
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Abbreviations
Government Performance and Results Act
Environmental Protection Agency
Research. Development, and Technical Services at EPA: A New
Beginning. July 1994, Report No. EPA/600/R-94/122
Office of Inspector General
Office of Regional Operations and State/Local Relations
Research Triangle Park
the Results Act
EPA
1994 Laboratory
Study
OIG
OROS/LR
RTF
IV
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CHAPTER 1
Introduction
PURPOSE
BACKGROUND
Regional Laboratories
Sources of
Analytical Services
The OIG performed an audit of EPA's regional laboratories. Although
prior OIG reports have addressed the Agency's Office of Research and
Development laboratories, there have been no recent reports concerning
the management of regional laboratories. Our objectives were to:
• determine whether improvements were needed in how regional
laboratories' activities were planned and managed, and
• identify areas where administrative processes among regional
laboratories could be streamlined.
A regional laboratory is located in each of the ten EPA regions. The
laboratories provide a range of scientific and technical services for a
wide variety of customers both internal and external to the Agency.
Customers include regional program offices and state and local agencies.
The laboratories' mission is to: (1) provide quality scientific data, (2)
integrate laboratory activities with field and quality assurance partners,
(3) maintain a fully equipped laboratory, (4) maintain and enhance a
technically and scientifically skilled staff, and (5) advance the Agency's
science agenda.
The focus of the regional laboratories is on the application of science
policies and methods in support of regulatory programs, monitoring
programs, and special projects. The laboratories' main role is to perform
sample testing in support of various regional programs. The regional
laboratories perform many special analytical services, which include fast
turnaround and verification analyses, nonstandard tests, and analyses
requiring low detection limits. Regional laboratories provide services
other than analytical support, including laboratory audits and
certifications, methods development, field sampling, consulting and
technical assistance, data validation, expert witness testimony, and
training.
EPA regions have three potential sources of laboratory services.
The two main sources are the regional laboratories and the Contract
Laboratory Program. As already mentioned, the regional laboratories
perform many special analytical services. The Contract Laboratory
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Program consists of a group of contractors that provides routine
analytical services in support of EPA's Superfund effort. Non-
Superfund programs may buy into these contracts if funds are available.
If a regional laboratory or the Contract Laboratory Program does not
have a certain capability, a region can obtain analytical services from
private laboratories through blanket purchase agreements, regional
contracts, or small purchase requests. For example, because Region 4
and the Contract Laboratory Program cannot perform dioxin analyses,
Region 4 contracts out for these services.
Government
Performance
and Results Act
The Government Performance and Results Act (the Results Act)
was enacted on August 3, 1993, to provide for the establishment of
strategic planning and performance measurement in the Federal
Government. Other purposes of the Results Act include:
• initiating program performance reform by setting program goals,
measuring program performance against those goals, and
reporting publicly on their progress; and
• improving Federal program effectiveness and public
accountability by promoting a new focus on results.
The intent of the Results Act is to change the culture of Federal
agencies, from focusing on what agencies are doing to what they are
accomplishing. Implementing the Results Act would improve agencies'
planning, budgeting, and accountability processes, linking them together
so that planning drives budgeting. Actual program results could also be
monitored and used to influence future planning.
To achieve a strong link among planning, budgeting, and accountability,
the Results Act requires all agencies to produce strategic plans, annual
performance plans, and annual performance reports. An agency's
strategic plan will include a comprehensive mission statement and
general objectives covering the major functions and operations of the
agency. Annual performance plans will include objective goals and
describe the operational processes and resources required to meet the
goals. Annual performance reports will assess the agency's performance
versus the established goals. The results will be used as a basis for
future decisions on programs and budgets.
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SCOPE AND
METHODOLOGY Our audit focused on the regional laboratories' management and
administrative processes and the Office of Regional Operations and
State/Local Relations (OROS/LR) role as the central advocate for the
regional laboratories. We performed fieldwork in Regions 4, 5, 8, and 9;
and at OROS/LR. We also obtained data from the other six laboratories.
We conducted fieldwork between July 8, 1996, and June 13, 1997.
To accomplish our objectives, we reviewed applicable policies and
guidance and interviewed EPA officials in the regions visited and
OROS/LR. As criteria, we used the Results Act, relevant EPA reports,
Office of Administration and Resources Management streamlining
guidance, and Office of Management and Budget information
management policies.
Our first objective was to determine whether improvements were needed
in how regional laboratories' activities were planned and managed.
Through reviews of documentation and discussions with laboratory,
regional, and OROS/LR officials, we evaluated the processes and
management controls used to plan, schedule, track, and report laboratory
activities. Laboratory activities include analytical tests, field sampling,
and laboratory inspections and certifications. We asked all ten regional
laboratories about their processes for scheduling, tracking, and reporting
activities, however we only requested data from the four regions visited.
We also reviewed all ten laboratories' processes for determining their
annual funding levels.
Our second objective was to identify areas where administrative
processes among regional laboratories could be streamlined including
equipment purchases, development of data management systems, and
standard operating procedures. To accomplish this, we asked laboratory
officials from all ten regions about their process for planning equipment
maintenance and purchases. We interviewed laboratory officials from
the four regions visited regarding their purchase and development of
data management systems.
We issued position papers to the regional laboratories and OROS/LR on
May 20, 1997. We met with both groups to discuss the position papers,
and incorporated their comments into the draft report. The draft report
was issued to the Acting Associate Administrator for OROS/LR on June
25, 1997. Comments to the draft report were received on July 29, 1997.
The comments were incorporated into the final report and included as
Appendix 1.
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We performed our audit in accordance with the Government Auditing
Standards. 1994 Revision, issued by the Comptroller General of the
United States, and included such tests as we saw necessary to complete
our objectives.
PRIOR AUDIT
COVERAGE There were no prior audits of EPA's regional laboratories related to the
objectives of our audit.
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CHAPTER 2
Improvements Needed to Meet The
Government Performance and Results Act
GOVERNMENT
PERFORMANCE
AND RESULTS ACT
To meet the Government Performance and Results Act of 1993 (the
Results Act), EPA is taking steps to improve the processes for planning,
program evaluation, budgeting, and fiscal accountability. The regional
laboratories' current processes will not be adequate to assist the Agency
in meeting the Results Act. Areas for improvement include: (1)
preparing performance plans, (2) measuring performance, (3) increasing
accountability, and (4) linking planning and performance to funding
levels.
Section 4 of the Results Act requires Federal agencies to prepare
performance plans and reports. By September 1997 and annually
thereafter, each agency is required to prepare a performance plan
covering the program activities set forth in its budget. These plans will:
• express objective, quantifiable, and measurable goals;
• establish performance indicators to be used in measuring or
assessing the relevant outputs, service levels, and outcomes of
each program activity; and
• provide a basis for comparing actual program results with the
established goals.
The Results Act also requires that starting March 31, 2000, each agency
will submit an annual report on program performance for the previous
fiscal year. The report will include the performance indicators
established in the plan along with the actual program performance
achieved as compared to the established goals. Also, where a
performance goal has not been met, the report will explain why the goal
was not met, the plans and schedules for achieving the goal, and whether
the goal is impractical or infeasible.
To help ensure compliance with the Results Act, EPA established a
Planning, Budgeting, Analysis, and Accountability process. Among
other items, it included requirements for annual performance plans and
reports. While the regional laboratories are not required to prepare their
own plans and reports, they provide important services to the program
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EPA's Regional Laboratories
offices and need to improve their planning process as EPA implements
the Results Act. Consistent planning methods throughout EPA,
including the regional laboratories, will simplify preparation of the
Agency-wide annual performance plans and reports.
CURRENT PRACTICES
NEED IMPROVEMENT
Preparing Annual
Performance Plans
The Results Act requires strong links among planning, reporting, and
budgeting; and increased accountability. To assist EPA in meeting these
requirements, regional laboratories, in conjunction with program offices,
will need to prepare annual plans with objective goals and performance
indicators and maintain consistent data on results. Regional laboratories
will then need to report to regional and program management on actual
achievements and costs versus projected levels. Lastly, the laboratories
will need to base the funding they receive on planned activities and
performance results. Performing these activities will help the regional
laboratories and the Agency determine whether goals are being met and
resources are being used for priority activities.
Annual performance plans under the Results Act will include
objective goals and performance indicators. According to a 1994 EPA
Subcommittee report2, regional laboratories generally lacked the
information required for effective planning. Only four often regional
laboratories prepared work plans that included goals and indicators.
Identifying these elements in annual plans will provide the laboratories
with a basis to compare to results and determine if objectives are being
achieved.
In 1994, the Subcommittee identified a weakness related to planning
among the regional laboratories. There was a general lack of readily
available information, particularly in the areas of resource management
and future program needs. This information was required to effectively
plan for the future. The Subcommittee recommended that EPA develop
an integrated process to plan its future, and evaluate its current, science
and technical service requirements. The ability to estimate current and
future needs would help the Agency develop performance plans. As of
June 1997, EPA had not taken action to address the recommendation.
Regional laboratories prepared annual plans with varying levels of
detail.
Research. Development, and Technical Services at EPA: A New Beginning. Appendix F, "EPA Laboratory
Study: BSD Evaluation - Cross-Agency Subcommittee Final Report", Report No.
EPA/600/R-94/122, July 1994.
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EPA's Regional Laboratories
• Half of the laboratories did not prepare written work plans.
Officials said planning specific activities was difficult because
the laboratories provided services in response to changing
regional needs.
• One laboratory prepared plans, but did not identify goals and
indicators. The work plans included narrative descriptions of
planned activities, based on regional priorities.
• Four laboratories' work plans included goals and indicators. For
example, one region included the estimated number of
inspections and investigations. Another region projected the
work days required to complete certain numbers of activities,
such as training and technical assistance. The plans did not
include estimated levels of analytical support the laboratories
would provide, although this was one of the laboratories' major
activities.
Regional and laboratory officials said that it was difficult to develop
detailed work plans because the regional laboratories provide a support
function and must react to changing program needs. However, the
laboratories perform many of the same types of functions every year. As
a result, laboratory officials can establish performance indicators and
goals for some activities, with the recognition that the laboratories also
fulfill special program needs that are not easily quantified.
Performance indicators are particular values or characteristics used to
measure or assess relevant outputs, service levels, and outcomes of
program activities. Based on the audit, we identified two potential
indicators for the regional laboratories.
• One indicator could be the number of analytical tests performed.
Often regions, nine counted analytical activities based on
analyses, which represented one sample through one instrument.3
A corresponding goal would be that the regional laboratory
would perform a certain number of analyses in a fiscal year.
• Another indicator could be the number of laboratory audits.
Regional staff audit contract laboratories to ensure they are
3Even if an instrument simultaneously tests for a number of elements, the activity is counted as one analysis.
However, there could be more than one analysis for each sample.
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EPA's Regional Laboratories
Measuring Performance
Results Consistently
Increasing Accountability
Through Reporting
properly analyzing samples. A related goal would indicate the
number of audits the region planned to conduct during the year.
To compare actual results to established goals on a national basis,
the regional laboratories need consistent data on achieved performance
levels. Comparing results to goals for analytical support will be difficult
because some regions include different items in the counts of analytical
activity. As a result, EPA will not be able to determine the national
performance level and whether the laboratories are meeting established
goals.
Laboratory officials included the standard analyses performed by
regional laboratory analysts in the analytical activity data. Also, two of
the ten regions included certain types of quality control work in their
data; the other eight did not. Including quality control analyses adds
significantly to the total analyses. For example, Region 8 included
quality control work in its data. In fiscal year 1996, Region 8's total was
over twice as high as Region 4's (see table 1). This occurred although
Region 8 had one of the smallest regional laboratories while Region 4
had one of the largest, based on the number of regional full-time
equivalents.
Table 1: Regions Included Different
Activities in Data
Region
4
8
Includes Quality
Control Work
No
Yes
Total
Analyses
11,230
22,849
One method of measuring analytical activity is not recommended over
the other. However, because of the differences in measuring, it would
not be possible for the Agency to compare data across the regions and to
calculate total analytical activities versus the projected level. The
regional laboratories need to determine a system for consistently
measuring analytical activities. This will allow determination of an
EPA-wide total and comparison of actual results to goals.
Accountability is a process for analyzing actual performance and
cost against goals and should focus on the Agency's accomplishments
relative to the commitments made in the annual performance plan.
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Regional laboratories would increase their accountability by preparing
annual performance reports that relate actual results and resources
expended to objectives.
Seven of the ten regional laboratories prepared activity reports and
submitted them to regional or program management. These reports
varied in terms of the information included. Some of the reporting
regions compared actual accomplishments to planned activities, while
others only described completed activities. Five of the seven regions
included numerical data on the levels of actual or planned performance.
The three remaining regional laboratories did not report laboratory
activities to regional or program management. Laboratory officials said
that some regional and program management did not request data on
actual levels of performance or resources used because they were
satisfied with the services provided. Also, the programs were not
concerned about the cost of services as long as analyses were performed
on time. Staff members from one region said they had not submitted
reports since 1995 because management was more interested in
environmental results. In another region, the laboratory previously
submitted detailed quarterly reports to program managers. Since the
managers provided little feedback, this practice was suspended.
The regional laboratories need to prepare performance reports to show
actual accomplishments and costs versus planned activities. Preparing
these reports will show whether the laboratories have met their goals and
where resources have been spent. Submitting these reports to program
and regional management will also increase the regional laboratories'
accountability.
Linking Funding to
Performance Plans
and Results
The Results Act emphasizes a strong link among planning,
reporting, and budgeting. EPA intends that performance plans and
prior years' results, including resources used, will be the basis for future
decisions on programs and budgets. However, only three often regional
laboratories used planned activities and prior years' results as the basis
for their budgets, while seven based their budgets on historical amounts.
Laboratory officials said that they do not believe they have significant
input into how much funding they receive. This occurs because regional
laboratories do not have a specific appropriation. Instead, they are
funded by other program offices or through the Regional Administrators'
offices.
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In terms of basing budgets on historical amounts, an EPA report4 stated
that: "The budget process should avoid focusing decisions solely on the
margin of the prior year's budget because this discourages consideration
of significant change or major redirection." As the laboratories and EPA
continue to implement the Results Act and prepare performance plans
and reports, the funding they receive should be based more on activities
and less on historical amounts.
CONCLUSION
RECOMMENDATIONS
The Government Performance and Results Act places new requirements
on Federal agencies for improving their planning, budgeting, and
accountability systems. Current regional laboratory practices will not be
adequate to assist the Agency in meeting the Results Act. The regional
laboratories can improve their planning processes by working with
program offices to prepare annual performance plans that include goals
and indicators and measuring performance results consistently. The
laboratories can: (1) increase accountability by preparing annual
performance reports and (2) develop a stronger link between funding
levels and performance plans and results. Performing these activities
will not only help EPA meet the Results Act, it will improve the overall
management of activities and resources at the laboratories.
We recommend that the Acting Associate Administrator for Regional
Operations and State/Local Relations work with regional laboratory
management to:
2-1. Prepare, in conjunction with program offices, annual
performance plans that include goals and performance indicators.
2-2. Develop a system that all regions will use to consistently
measure laboratory activities.
2-3. Prepare annual performance reports that compare goals with
actual accomplishments.
2-4. Base funding levels on performance plans and prior years'
results.
AGENCY ACTIONS
Managing For Results. The Planning, Budgeting, and Accountability Task Force, February 23, 1996.
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In responding to the draft report, the Acting Associate Administrator for
Regional Operations and State/Local Relations agreed with all the
recommendations and stated that the regional laboratories have taken,
and will continue to take, action to address the recommendations.
2-1. The regional laboratories are working with the program offices,
the Office of Planning, Analysis and Accountability, and the
Office of Regional Operations and State/Local Relations to meet
the requirements of the Results Act. The regional laboratories
have developed an overall objective and sub-objectives, and are
working on specific performance measures and a performance
plan. The performance plan will be completed by the end of
fiscal year 1998.
2-2. The regional laboratories agree that a consistent measurement
system should be developed, and the issue will be discussed at a
meeting in September 1997. However, they believe that it is
important to develop a system that is not only consistent and
accurate, but also reflects other factors and assumptions that
need to be considered when measuring the performance of
regional laboratories. A pilot evaluation system will be
completed by September 1998.
2-3. In accordance with the Results Act, the regional laboratories will
prepare annual performance reports that will compare actual
accomplishments with established goals. The first report is due
March 31, 2000, which will address the accomplishments for
fiscal year 1999.
2-4. The regional laboratories anticipate that funding decisions will
be based on accomplishment of goals as identified in
performance plans. The full system for linking planning,
budgeting, and accomplishments should be in place for the
development of the fiscal year 2002 budget. Interim efforts will
be made to assure maximum accountability.
OIG EVALUATION
The Agency's planned actions will address the recommendations.
CHAPTER 3
Regional Laboratories Need a Stronger
Shared Identity and National Leadership
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EPA's regional laboratories need a stronger shared identity and more
active national leadership. Each regional laboratory has historically
operated independently of the others, however, there are many
similarities in their missions, goals, and contributions to the Agency. A
1994 EPA report5 (1994 Laboratory Study) recommended enhancing the
role of the "central advocate"for the regional laboratories and re-
evaluating which organizational component should fill that role.
Although the Office of Regional Operations and State/Local Relations
(OROS/LR) was designated to perform this role, its ability to fulfill the
responsibilities had been limited due to resource constraints.
The absence of a shared identity among regional laboratories and the
limited scope of national leadership have resulted in inefficient efforts to
meet common needs. Development of a data management system and
procurement of capital equipment are two examples of where
uncoordinated efforts caused duplication of effort. A stronger shared
identity and more active leadership would help the laboratories achieve
efficiencies from their collective efforts.
SHARED IDENTITY
Each of EPA's ten regional laboratories has historically seen itself as a
unique entity. Laboratory officials have no responsibility to each other
or to a national level office within EPA. Instead, each regional
laboratory reports to its respective Regional Administrator. At the same
time, regional laboratories share similarities in their missions, goals, and
contributions to EPA. Each provides a wide range of technical support
and assistance services to regional program offices, state and local
environmental agencies, and tribal units for use in environmental and
enforcement decision-making. Specific activities include sample
analysis, method development, and laboratory inspection and
certification.
Regional laboratories are not, and should not be, identical in their size,
structure, or method of delivering services. Geographic and program
variations mandate that each laboratory has the flexibility to meet unique
requirements. However, the laboratories need to accept and embrace
that there are significant similarities in the functions they perform. The
regional laboratories prepared a draft vision statement that indicated
Research. Development, and Technical Services at EPA: A New Beginning. Report No.
EPA/600/R-94/122, July 1994.
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that, more and more, solutions to environmental problems can be
achieved only through the collective efforts of all stakeholders. A
stronger shared identity and national leadership will assist the
laboratories in considering not only their regional needs, but national
needs that can be met through coordinated efforts.
NATIONAL
LEADERSHIP The laboratories continue to need stronger national leadership.6 In the
1994 Laboratory Study, EPA concluded that it needed to strengthen the
Headquarters advocacy for the regional laboratories. This would, in
essence, place regional laboratories on a par with national program
offices. This organization would serve a two-fold role. First, it would
represent the regional laboratories within Agency-level issues. These
would include discussions concerning allocation of resources. Second,
the organization would serve as a focal point for regional laboratory
functions. This would include identifying efficiencies related to
coordination of laboratory functions and encouraging cooperation
among the laboratories. However, according to EPA officials, the
expanded role EPA envisioned has not been fulfilled due to resource
constraints.
The 1994 Laboratory Study listed the following activities among the
central advocate's proposed roles:
• provide consensus building for the effective and efficient use of
resources to meet support requirements;
• facilitate communications among the laboratories, the
Administrator, and program offices;
• ensure that senior management understood how the laboratories'
mission integrates into EPA's overall scientific mission;
• represent the laboratories during budget and strategic planning
efforts; and
• provide leadership for the laboratories promoting national
consistency.
6The regional laboratories have referred to this role as the "central advocate". However, in the context of
this report, we will refer to it as "leadership" to better include all aspects of the envisioned role.
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The study recommended that OROS/LR continue as the central advocate
with enhanced management and budget support. However, according to
an OROS/LR official, it was not able to fulfill this enhanced role due to
limited resources. The OROS/LR's activities for regional laboratories
had been limited to budget justification and distribution of resources for
capital equipment.
The regional laboratory managers believe that stronger national
leadership is needed. The managers provided the following areas of
deficiencies which highlight the need for stronger leadership:
• liaison between the laboratories and Headquarters program
offices, resulting in less than full integration of the regional
laboratories into the Agency's science program,
• communication between Headquarters and the laboratories
concerning emerging issues that may affect its operation and
results in under-utilization of resources,
• advocacy or leadership when budget and staffing levels are
addressed,
• promotion, at the national level, of the regional laboratories'
functions and contribution to the Agency, and
• recognition of the role that regional laboratories play in
enforcement, monitoring, and agency initiatives.
OROS/LR is currently undergoing a reorganization and redefinition of
duties. As part of the reorganization, Agency management has decided
that regional laboratory leadership will remain with the regional
operations staff in the Office of the Administrator. As EPA implements
the reorganization, it needs to determine what role the regional
operations staff will perform. In doing so, it is essential that the regional
operations staff provide stronger national leadership.
ILLUSTRATIONS OF
NEED FOR NATIONAL
LEADERSHIP
The absence of: (1) a shared identity and (2) an effective national
leadership have resulted in inefficient use of resources. Attempts to
develop data management systems within regional laboratories and the
procurement of capital equipment are two examples of where national
leadership may have resulted in a more efficient use of resources. A
stronger shared identity and national leadership will assist the
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laboratories in considering not only their individual needs, but how their
needs impact and overlap the needs of other laboratories.
Data Management Each regional laboratory has independently purchased, or
Systems developed, its own data management system. While actual use varied,
each laboratory's data management system had the capability to perform
some similar functions. In 1992, EPA's Research Triangle Park (RTF)
and regional laboratories attempted to develop a common system that
would address the core needs of all of the laboratories. However, in
spite of its efforts and investments, EPA does not have a data
management system which meets the laboratories' needs.
The RTF system was designed to contain a core set of functions that all
of the laboratories needed such as project management, sample tracking,
and analysis scheduling. The data management system was provided to
interested regions. However, only a few regions adopted it as the others
felt the system was not adequate. Some of the regional laboratories felt
that this system did not meet the needs already met by current systems,
was not user friendly, and that it had flaws. For example, the system did
not: (1) meet biologists' needs, (2) electronically transfer data, or (3)
generate reports. As a result, regional data management needs have
been met through several different efforts.
A comparison of Region 5's and 9's systems shows the variations in how
the systems are used and the related costs.
• Region 5 uses its system to track workload, track samples,
generate reports, and upload information from instruments.
Region 9 currently only uses its system to log in samples.
• Region 5 obtained its system at no cost from RTF. Region 9
purchased a commercial system for about $10,000.
• Region 5 had recently modified its system to expand its
capabilities. Region 9 was hiring computer support to learn the
capabilities of its system.
The comparison of the systems shows the differences that exist
throughout regional laboratories. Both regions spent time and resources
trying to get a reliable system in operation. A stronger national
leadership would prevent further duplication of effort in the purchase,
development, or modifications of systems needed to meet the regional
laboratories' core needs. This leadership could facilitate communication
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among the laboratories to determine the universal needs for a system,
capabilities that had already been developed, and on-going regional
developments. Coordination of data management system development
would result in a more consistent national process for tracking
laboratory activities.
Equipment Purchases
CONCLUSION
Regional laboratories' capital equipment purchases were made based on
regional rather than national needs. As a result, regional laboratories
have the potential for inefficient use of equipment resources. If
equipment purchases were better coordinated, regional laboratories
could reduce the potential for purchasing equipment that would not be
fully used. EPA and the regional laboratories have also recognized the
need for better coordination, but have not taken action to improve it.
While OROS/LR was responsible for ensuring proper use of the capital
equipment funds, it did not centrally manage the equipment purchases,
nor did it require the regional laboratories to submit information on
planned purchases and the rationale for those purchases. In December
1996, the OROS/LR began developing a tracking system to show
equipment purchased since 1992. An OROS/LR official stated that
requiring laboratories to submit the information increased their
accountability for the funds. However, OROS/LR's tracking system
only identifies past equipment purchases and does not account for
planned purchases. As a result, the current method of tracking will still
not prevent regional laboratories from purchasing duplicate equipment
that will be underutilized.
Regional laboratories have recognized that there may be a more efficient
way of using equipment. A draft vision statement for the regional
laboratories indicated that the regions would coordinate workload,
equipment, and expertise among themselves to assure the most efficient
and highest quality service. Under this vision, regional laboratories
might use equipment resources more efficiently through coordination of
equipment purchases. National leadership for the regional laboratories
could help the regional laboratories identify a better way to use
resources to meet support requirements. This leadership could bring the
laboratories together to recognize there are commonalities in their work
and that they can provide support not only to their regions but also to
each other.
EPA's regional laboratories need a stronger organizational identity and
national leadership. Each regional laboratory has historically operated
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independently of the others, however, there are many similarities in
terms of their missions, goals and contributions to the organization. The
enhanced national leadership role EPA envisioned is currently not being
fulfilled. A stronger shared identity and national leadership could help
regional laboratories improve coordination of their activities to reduce
duplication of effort and achieve efficiencies in the use of resources.
RECOMMENDATIONS
AGENCY ACTIONS
OIG EVALUATION
We recommend that the Acting Associate Administrator for Regional
Operations and State/Local Relations:
3-1. Work along with the regional laboratories to complete their
efforts to develop a common vision and mission statement.
3-2. Work with regional laboratory management to identify the
appropriate responsibilities for the national leader.
In responding to the draft report, the Acting Associate Administrator for
OROS/LR agreed with the recommendations and described actions to
address the recommendations.
3-1. The regional laboratory vision and mission statements should be
completed by January 1998.
3-2. During the current reorganization, OROS/LR discussed with the
Regional and Deputy Regional Administrators and regional
laboratory directors the specific responsibilities for the national
leader. Within one month of finalizing the reorganization plan, a
work plan will be developed to reflect regional operations staff
activities in support of regional laboratory operations.
The Agency's planned actions will address the recommendations.
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Appendix 1
Page 1 of 3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, B.C. 20460
Office of Regional Operations
and State/Local Relations
MEMORANDUM
DATE: July 29, 1997
SUBJECT: Response to the Draft Audit Report No. E1PMF6-05-0115, Audit of
Regional Laboratories
FROM: Marylouise M. Uhlig
Acting Associate Administrator
TO: Michael Simmons
Deputy Assistant Inspector General for Internal Audits
On behalf of the Regions and OROS/LR, I want to thank you for the opportunity to review the
Draft Audit Report No. E1PMF6-05-0115, Audit of Regional Laboratories. Charles Allberry, Audit
Manager, Northern Audit Division and his staff conducted a highly professional review of the planning
and management processes of the Regional laboratories. Evaluations of this kind are very useful to
management serving as important tools in our efforts to improve and streamline operations.
The Office of Regional Operations and State/Local Relations (OROS/LR) and the Regional
Science and Technology (RS&T) Managers have joined with the Agency in its efforts to understand and
implement the specific requirements and goals behind the Government Performance and Results Act
(GPRA). We recognize the importance of both planning and accountability and will continue recent
ongoing efforts to bring our processes in line with GPRA requirements. Supporting the concept of a
shared identity for the Regional laboratories, the Regional Operations Staff will work with the Regions to
achieve greater consistency and effectiveness through more coordinated efforts across the Regional
laboratories. As the reorganization of portions of the Office of the Administrator, including the Regional
Operations Staff (ROS), is implemented, the ROS will work to acquire the resources (FTE) necessary to
provide strong national leadership for the broad scope of issues vital to the Regional Science and
Technology organizations.
Note: The original response was signed by Bettina B. Fletcher for Marylouise M. Uhlig.
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Appendix 1
Page 2 of 3
In response to your specific recommendations, we offer the following comments, planned
corrective actions and time frames for accomplishing these remedies.
Recommendation 2-1
The Regional laboratories are working with Program components, the Office of Planning,
Analysis and Accountability, and OROS/LR to meet the requirements of GPRA. The RS&T
organizations have developed an RS&T Objective under Agency Goal 8, Sound Science, and a draft
Profile Planning Baseline to accompany the Objective. Also, an RS&T GPRA Workgroup comprised of
representatives from each RS&T, have developed Sub-objectives that further define the RS&T Objective
and provide specific Performance Measures. The RS&T GPRA Workgroup will continue to respond to
all Agency GPRA requirements for implementation. The next step will be the development of the
Performance Plan with Goals and Performance Indicators. The time frame for complete implementation
of this recommendation according to the Agency's GPRA schedule will be the end of FY 1998 for FY
1999.
Recommendation 2-2
The RS&Ts have had numerous discussions concerning the issue of measuring laboratory
activities consistently across the Regions. The RS&Ts agree that a consistent measurement system
should be developed and this issue will be on the agenda for the fall RS&T meeting in September, 1997.
However, the RS&Ts believe that it is important to develop a laboratory activities measurement system
that is not only consistent and accurate, but also reflects numerous other factors and assumptions which
impact any algorithm used to measure laboratory performance. Sample matrix complexity, programmatic
requirements, temporal sample loading patterns, data quality objectives (e.g. from enforcement-quality
requirements to initial site screening), appropriate quality assurance levels all significantly impact the
number of samples analyzed by a laboratory. A mechanism to measure Regional laboratory activities,
including consideration of the additional factors, will be prepared for pilot evaluation by September,
1998.
Recommendation 2-3
In accordance with GPRA, the RS&Ts will join the Agency in preparing annual Performance
Reports that compare actual accomplishments with established goals. Laboratory performance will be an
important element of these reports. The first steps in this process have already been taken with the
development of the RS&T Objective, Sub-objective and Performance Measures under GPRA.
Implementation of this recommendation will follow the Agency GPRA requirements with the first
Annual Performance Reports due March 31, 2000 addressing accomplishments for FY 1999.
Recommendation 2-4
The RS&Ts anticipate that funding decisions will be based on the accomplishment of Goals as
outlined in their respective Performance Plans. Performance Plans with their Performance Indicators will
be incorporated with the Annual Performance Reports and Program
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Appendix 1
Page 3 of 3
Office guidance concerning areas of investment and disinvestment to establish outyear funding
requests. Implementation of this recommendation will follow the Agency schedule which calls for
the completion of Annual Performance Reports by March 31, 2000 addressing the accomplishments of
FY 1999. Accordingly, the full GPRA system to link planning and budgeting should be in place for the
Regional laboratories for development of the Agency's FY 2002
budget. Interim efforts will be made to assure maximum accountability of Regional laboratories as
rapidly as possible.
Recommendation 3-1
OROS/LR is actively engaged with the RS&T managers to complete development of a common
vision and mission statement for the Regional laboratories. The vision and mission statements will be
discussed with Senior Regional management as well as Headquarters Program Offices to assure that there
is a shared understanding and support for the functions which the Regional laboratories can and should
provide for the Agency. We anticipate that the vision and mission statements should be in place by
January, 1998.
Recommendation 3-2
OROS/LR, in the context of recent Office Reorganization activities, initiated a dialogue with
both the RS&T managers and Regional and Deputy Regional Administrators concerning the
specific responsibilities for the national leader of the RS&Ts. The need for improved coordination
among Regional laboratories for greater efficiency and effectiveness is recognized and will be
incorporated in the activities of the successor organization, the Regional Operations Staff (ROS) The
scope of the functions which can be carried out will be dependent upon the staffing levels which can be
established for this activity.
OROS/LR's has a long history with the Regional laboratories; this experience and expertise will
continue through the Regional Operations Staff. There is a strong commitment on the part of the Office
of the Administrator, including the Regional Operations Staff, to provide the National leadership to the
Regional laboratories to maximize their ability to support the Agency's mission for protection and
improvement of public health and the environment. As soon as the Office of the Administrator
Reorganization is finalized, a work plan will be developed for Regional Operations Staff activities in
support of the RS&T operations. This work plan will reflect discussions with RS&T managers, Regional
Administrators and Deputy Regional Administrators and will define the responsibilities of this National
leadership role. The draft workplan will be developed within one month of the completion of the
Reorganization.
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Appendix 2
Page 1 of 1
DISTRIBUTION
Headquarters
Acting Associate Administrator for Regional Operations and
State/Local Relations (1501)
Assistant Administrator, Office of Research and Development (8101)
Audit Followup Coordinator, Office of the Administrator (1104)
Agency Followup Official (3101)
Attn: Assistant Administrator, OARM
Agency Followup Coordinator (3304)
Attn: Director, RMD
Associate Administrator for Congressional and Legislative Affairs (1301)
Associate Administrator for Communications and Public Affairs (1701)
Headquarters Library (3404)
Office of Inspector General
Inspector General (2410)
GAO Issue Area Planner
Divisional Inspectors General
Regional Offices
Regional Administrators
Regional Laboratory Directors
Regional Libraries
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